(Attempt to Provide Material Support to a Foreign Terrorist Organization)

The Grand Jury Charges That:

From in or about December 2013 to on or about May 31, 2014, in the Western District
of New York, the defendant, MUFID A. ELFGEEH, a citizen of the United States,
knowingly did attempt to provide material support and resources, as that term is defined in
Title 18, United States Code, Section 2339A(b), that is, personnel, specifically, a person
known to the grand jury and identified here as Individual A, to a designated foreign terrorist
organization, namely the Islamic State of Iraq and the Levant (“ISIL”) a/k/a the Islamic
State of Iraq and Syria (“ISIS”) a/k/a ad-Dawla al-Islamiyya fi al-‘Iraq wa-sh-Sham a/k/a
Daesh a/k/a Dawla al Islamiya, knowing that ISIL/ISIS was a designated foreign terrorist
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organization, had engaged and was engaging in terrorist activity, as that term is defined in
Title 8, United States Code, Section 1182(a)(3)(B), and had engaged and was engaging in
terrorism, as that term is defined in Title 22, United States Code, Section 2656f(d)(2).
All in violation of Title 18, United States Code, Section 2339B(a)(1).

COUNT 2

(Attempt to Provide Material Support to a Foreign Terrorist Organization)

The Grand Jury Further Charges That:

From in or about December 2013 to on or about May 31, 2014, in the Western District
of New York, the defendant, MUFID A. ELFGEEH, a citizen of the United States,
knowingly did attempt to provide material support and resources, as that term is defined in
Title 18, United States Code, Section 2339A(b), that is, personnel, specifically, a person
known to the grand jury and identified here as Individual B, to a designated foreign terrorist
organization, namely the Islamic State of Iraq and the Levant (“ISIL”) a/k/a the Islamic
State of Iraq and Syria (“ISIS”) a/k/a ad-Dawla al-Islamiyya fi al-‘Iraq wa-sh-Sham a/k/a
Daesh a/k/a Dawla al Islamiya, knowing that ISIL/ISIS was a designated foreign terrorist
organization, had engaged and was engaging in terrorist activity, as that term is defined in
Title 8, United States Code, Section 1182(a)(3)(B), and had engaged and was engaging in
terrorism, as that term is defined in Title 22, United States Code, Section 2656f(d)(2).
All in violation of Title 18, United States Code, Section 2339B(a)(1).

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COUNT 3

(Attempt to Provide Material Support to a Foreign Terrorist Organization)

The Grand Jury Further Charges That:

From in or about February 2014 to in or about March 2014, in the Western District of
New York, the defendant, MUFID A. ELFGEEH, a citizen of the United States, knowingly
did attempt to provide material support and resources, as that term is defined in Title 18,
United States Code, Section 2339A(b), that is, personnel, specifically, a person known to the
grand jury and identified here as Individual C, to a designated foreign terrorist organization,
namely the Islamic State of Iraq and the Levant (“ISIL”) a/k/a the Islamic State of Iraq and
Syria (“ISIS”) a/k/a ad-Dawla al-Islamiyya fi al-‘Iraq wa-sh-Sham a/k/a Daesh a/k/a
Dawla al Islamiya, knowing that ISIL/ISIS was a designated foreign terrorist organization,
had engaged and was engaging in terrorist activity, as that term is defined in Title 8, United
States Code, Section 1182(a)(3)(B), and had engaged and was engaging in terrorism, as that
term is defined in Title 22, United States Code, Section 2656f(d)(2).
All in violation of Title 18, United States Code, Section 2339B(a)(1).

COUNT 4

(Attempt to Kill Officers and Employees of the United States)

The Grand Jury Further Charges That:

From on or about December 9, 2013, to and including May 31, 2014, in the Western
District of New York, the defendant, MUFID A. ELFGEEH, with premeditation and
malice aforethought, did unlawfully attempt to kill officers and employees of the United
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States, namely current and former members of the United States military, on account of the
performance of their official duties.
All in violation of Title 18, United States Code, Sections 1114(3) and 1113.

COUNT 5

(Possession of Firearms and Silencers in Furtherance of a Crime of Violence)

The Grand Jury Further Charges That:

On or about May 31, 2014, in the Western District of New York, the defendant,
MUFID A. ELFGEEH, in furtherance of a crime of violence for which he may be
prosecuted in a court of the United States, that is, a violation of Title 18, United States Code,
Section 1114(3), as set forth in Count 4 of this Indictment, the allegations of which are
incorporated herein by reference, knowingly and unlawfully did possess firearms equipped
with firearm silencers, namely, one (1) Glock 26, 9 millimeter handgun equipped with a
silencer, and one (1) Walther PPK, .32 caliber handgun equipped with a silencer.
All in violation of Title 18, United States Code, Sections 924(c)(1)(A) and
924(c)(1)(B)(ii).

COUNT 6

(Possession of Unregistered Firearm Silencer)

The Grand Jury Further Charges That:

On or about May 31, 2014, in the Western District of New York, the defendant,
MUFID A. ELFGEEH, knowingly did receive and possess a firearm, that is, a firearm
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silencer for a Glock 26, 9 millimeter handgun, not registered to him in the National Firearms
Registration and Transfer Record.
All in violation of Title 26, United States Code, Sections 5841, 5861(d), and 5871.

COUNT 7

(Possession of Unregistered Firearm Silencer)

The Grand Jury Further Charges That:

On or about May 31, 2014, in the Western District of New York, the defendant,
MUFID A. ELFGEEH, knowingly did receive and possess a firearm, that is, a firearm
silencer for a Walther PPK, .32 caliber handgun, not registered to him in the National
Firearms Registration and Transfer Record.
All in violation of Title 26, United States Code, Sections 5841, 5861(d), and 5871.

DATED: Rochester, New York, September 16, 2014.

WILLIAM J. HOCHUL, JR.
United States Attorney

BY: s/Brett A. Harvey
BRETT A. HARVEY
Assistant United States Attorney
United States Attorney's Office
Western District of New York
500 Federal Building
100 State Street
Rochester, New York 14614
(585) 399-3949
Brett.Harvey@usdoj.gov

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BY: s/Frank H. Sherman
FRANK H. SHERMAN
Assistant United States Attorney
United States Attorney's Office
Western District of New York
500 Federal Building
100 State Street
Rochester, New York 14614
(585) 399-3934
Frank.Sherman@usdoj.gov